Meredith v. Commonwealth

Summary

The Supreme Court of Kentucky reviewed Richard Allen Meredith's convictions for complicity to commit murder and complicity to commit first-degree robbery. The court held that sufficient circumstantial evidence supported both convictions and that evidence concerning Meredith's child-support arrearage was admissible to show motive. A separate opinion concurred in part and dissented in part, concluding that the evidence did not establish the mental state required for complicity to commit murder.

Holdings

1. The evidence was sufficient for a reasonable jury to find that Meredith provided Crain transportation to and from Harold's Hubcaps with the intention of promoting or facilitating first-degree robbery. The trial court therefore properly denied a directed verdict on the robbery charge.
2. The evidence was sufficient to support Meredith's conviction for wanton murder as a complicitor under KRS 502.020(2) and KRS 507.020. Kentucky's former felony-murder doctrine could not independently establish homicide liability, but a participant in the underlying felony may be liable for a resulting death when the participant's conduct constitutes wantonness manifesting extreme indifference to human life.
3. The child-support evidence was admissible under KRE 404(b) as relevant and probative evidence of Meredith's motive to commit the robbery, and Meredith failed to preserve any challenge to the evidence because he raised no further objection after the trial court excluded details of the child-support proceedings.

Questions Presented

1. Whether the evidence was sufficient to deny a directed verdict on complicity to commit first-degree robbery.
2. Whether the evidence was sufficient to deny a directed verdict on complicity to commit murder under Kentucky's complicity and homicide statutes.
3. Whether evidence that Meredith was in child-support arrears and needed money was admissible to show motive for the robbery and whether the issue was preserved for review.

Disposition

affirmed